CST Privacy Policy

C.S.T. Savings Inc., C.S.T. Spark Inc., the Canadian Scholarship Trust Foundation, and their respective employees, licensed sales representatives and mutual fund representatives (collectively, "CST") are committed to taking steps to preserve and safeguard your right to privacy. As part of this commitment, we want you to be fully aware of what happens to your personal information, which we have in our possession. This Privacy Policy sets out the manner in which we will collect, use, disclose and otherwise manage your personal information. 

Information You Provide:

CST is required under securities legislation and anti-money laundering legislation to collect certain information to verify the identity of clients, to meet its regulatory obligations when opening a new account, recommending an investment and/or administering an RESP. The information we collect about you is limited to that which is necessary for our purposes, and it is retained in a client record.

You provide most of this information in one of the following ways:

• to one of our licensed sales representatives when you complete an application form to become a subscriber to one of our CST Registered Education Savings Plans ("RESP")
• to one of our mutual fund representatives when you complete the new client account and Registered Education Savings Plan (‘RESP’) applications forms or use our self-serve website to complete these forms.

The personal information in your client record includes:

• Your name, address, email address, occupation, and birth date;
• Your social insurance number for income tax reporting and other government purposes;
• Your financial information including information related to your financial institution(s) and bank account information, and your estimated annual family disposable income and liquid net worth;
• Information about your investor profile;
• Information about beneficiaries such as the name, address, birth date and social insurance number of the child(ren) designated to receive benefits under your RESP; and,
• Information we need in the course of the administration of your RESP such as tax records, school transcripts, and other documentation necessary to support claims or requests for various types of payments and benefits.

We also collect information about you when you complete an application form for a Founders’ Award or bursary and retain it in an award/bursary record. The personal information in your Founders’ Award or bursary record may include:

• Your name, address, email address, occupation, and birth date;
• Your financial information including annual income to demonstrate financial need;
• Information we may need in the course of the administration of your award or bursary and documentation necessary to support claims or requests for various types of payments.

We may collect personal information, such as your name, contact information and information relating to the number and ages of your children, on a CST contest ballot or promotional entry form. We collect this information for the purpose of administering a contest or promotion. If you voluntarily provided your consent to be contacted to learn more about RESPs, the government grants and/or the Canadian Scholarship Trust Plan, and/or CST Spark Education Portfolios, a licensed sales representative or one of our mutual fund representatives, respectively, may contact you. We do not require such consent as a condition of your participation in the contest or promotional activity.

Automatic Collection:

We receive and store certain types of information when you interact with our websites, including use of the self-serve website. This may include information such as the type of internet browser or computer operating system you are using, the domain name of the website from which you linked to the website, the date and time you visit the website and the pages you visit on the website. In addition, when you view the website, we may store some information on your computer in the form of a “cookie”. Cookies are small pieces of data which are stored on your computer to allow your internet browser to remember something about a website, and for us to identify your computer and provide us with a record of your visits to our website. This statistical information helps us to understand how our website is used (e.g., which pages or sections are most popular and when are the peak activity times), which assists us in planning for future improvements to the site to better meet our visitors’ needs. At your option, you may turn off our cookies using the application features contained in your internet browser; however, doing so may prevent you from accessing all or parts of the website. We do not link your cookies to other personally identifiable information about you.

Social Media

We may offer you the opportunity to engage with us through third-party social networking websites, plug-ins, and applications. Through these platforms, you may provide us with personal information or allow us to access information associated with your social media account. We may use this information to confirm your identity, respond to your posts or other inquiries and to personalize your experience on our website.

Information from Other Sources:

We may collect personal information about individuals you or other sources refer to us, such as their name, contact information and information relating to the number and age range of their children. We collect this information for the purpose of marketing products and services that you or the other sources believe may be of interest to them. We will not use this information for any other purpose without their consent. We will contact such individuals using the telephone number, residential address, or e-mail or other electronic address you or the other source have given us and will provide your name or identify the other source in any such communication. If the individual referred does not want us to keep their information, we will remove it at their request (see “Withdrawing Your Consent” below).

We collect and use your personal information for one or more of the following purposes:

• To identify who you are;
• To understand your needs;
• To assess whether the recommended investment is suitable for you;
• To establish and administer your RESP;
• To provide you with financial statements, tax receipts and other information about your RESP;
• To improve our service offerings;
• To evaluate your Founders’ Awards or bursary application;
• To improve our website;
• To meet our legal and regulatory requirements;
• To manage and assess our risks;
• To protect us from error and to prevent or detect fraud or criminal activity; and,
• To administer a contest or promotional activity.

We may share your personal information among the CST entities listed above when you apply for, or to determine if you may qualify for, a new product or service. We may also share your personal information among CST entities to keep your contact information and other personal information accurate and up-to-date, and to better manage your relationship with us. For example, if you update your personal information with one entity, we may use this information to update our records on other CST platforms. 

We do not directly provide all the services related to your relationship with us. We may use third party service providers to process or handle personal information on our behalf and to assist us with various services such as the preparation and mailing of client statements, data processing, award application administration, document storage and contest or promotional activity administration. Some of our service providers are located and/or store data outside of Canada, including in the European Union (EU) and United States (US). We require our service providers to maintain the confidentiality and security of personal information and do not authorize them to use or disclose personal information for any purpose outside of Canada, and for any purpose other than providing the services on our behalf or as otherwise required by applicable law. 

We, or our trusted retail partners, may ask you for your contact information, such as your telephone number, residential address, e-mail, or other electronic address for the purpose of marketing products and services that we believe may be of interest to you. We keep and use this information so that we may contact you directly through these channels for the purpose of marketing including telemarketing. Your consent to this is not a condition of doing business with us and you may withdraw it at any time (see “Withdrawing Your Consent” below). 

From time to time, we may also send you information about products and services offered by third parties that we believe may be of interest to you, but we do not provide your name and contact information to any third parties for marketing purposes. 

We disclose personal information in your client record to Employment and Social Development Canada (ESDC), Canada Revenue Agency, Revenu Quebec and any other government body necessary for the purposes of administering your RESP(s), and to otherwise comply with legal and regulatory requirements. We only disclose the information that is reasonably necessary for you to obtain the benefits of your RESP.

Certain personal information in a client record may be shared with the custodial parent of a beneficiary of an RESP. 

We disclose personal information in your Founders’ Award or bursary record to Canada Revenue Agency for the purposes of administering our programs, and to otherwise comply with legal and regulatory requirements. We only disclose the information that is reasonably necessary.

CST and its Canadian, EU, US and other third-party service providers may provide your personal information in response to a search warrant or other legally valid inquiry or order (including lawful access by EU, US or other courts or governmental authorities), to an investigative body or as required by applicable Canadian, EU, US or other law. We may also disclose personal information where necessary for the enforcement or protection of our legal rights, to investigate or prevent loss or harm to persons or property, or as otherwise permitted by law.

We may also disclose your personal information in connection with a change in corporate control such as merger, acquisition, sale, reorganization, transfer, or stock sale. 

Except as set out above, we will not otherwise sell, transfer, or disclose any of your personal information to any third party without your knowledge and consent unless required or permitted by law.

Subject to legal, regulatory, and contractual requirements, you may refuse to consent to our collection, use or disclosure of your personal or business information, or you may withdraw your consent to our further collection, use or disclosure of your information at any time in the future by giving us reasonable notice. Depending on the circumstances, however, withdrawal of your consent may impact our ability to provide you or continue to provide you with some products, services or information that may be of value to you and may result in you or your beneficiary not being able to receive benefits that you would otherwise be entitled to under your RESP. We will act on your instructions as quickly as possible but there may be certain uses of your information that we may not be able to stop immediately. 

Where appropriate, we will ask for your consent to send commercial electronic messages, such as e-mail. You may withdraw your consent to receive emails about other products and services offered by CST or its marketing partners excluding emails directly related to the administration of your account at any time by clicking the “Unsubscribe” link provided in the email. Alternatively, you may contact us or your licensed sales representative using the contact information provided in the email to be removed from our mailing list.

Even if you have opted out of receiving marketing communications from us, please be aware that we may still contact you for other purposes. For example, we may contact you to provide communications you have consented to receive, regarding the services we provide to you, or if you contact us with an inquiry.

Our website may include links to third party websites. Except as outlined in this Privacy Policy, we will not provide any of your personal information to these third parties without your prior consent. CST provides links to third party websites as a convenience to the user. The inclusion of any link does not imply CST’s endorsement of any other company, its websites, or its products and/or services. These linked websites have separate and independent privacy policies, which we recommend you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use or disclose and otherwise treat your personal information.

We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control. We will maintain the strict confidentiality of all personal information collected and will only disclose such information to employees and authorized contractors of CST who require such information for the purposes set out above. We will keep your personal information for as long as it remains necessary or relevant for the purposes stated above or as otherwise required by law. Even after you cease to be a CST client, we keep some information about you on file in order to meet certain legal requirements.

If you would like to review or update the personal information in your client record or if you have any inquiries or comments about this Privacy Policy, please contact CST’s Chief Privacy Officer by mail at: CST Savings Inc., 1600-2235 Sheppard Avenue East, Toronto ON M2J 5B8 or by e-mail at [email protected]. 

We may amend this Privacy Policy from time to time to take into consideration changes in legislation or other issues that may arise. The most up-to-date version of our Privacy Policy is always available on our public website.

Last Updated: August 2023